Privacy Policy

This Privacy Policy explains how Clintara, LLC ("Clintara") handles personal information.
"Personal information" is defined as information submitted to and/or collected by
Clintara via our company website. Such information can be collected when an individual
submits his or her name and/or address. Clintara can also collect information about
visits to the Clintara website without an individual actively submitting information
through various automated digital means, such as cookies and internet tags. Although
the information collected by such automated digital means does not directly identify
specific individuals, internet web browsers automatically transmit information to
the Clintara website regarding the software a user's computer is operating, such
as IP Address and browser version. Information collected by these technologies cannot
be used to identify individuals without additional identifiable information.

Any identifiable information individual users provide will be used only by Clintara
employees for the purposes of fulfilling a specific client request. Clintara will
not share this information with any third party without the consent of an individual
user. Clintara will not disclose any Personally Identifiable Information it gathers
from an individual user, except as set forth in this Privacy Policy or as specifically
agreed to by such individual user. Clintara may release Personally Identifiable
Information to third parties without user consent: (1) to comply with valid legal
requirements such as a law, regulation, search warrant, subpoena or court order;
or (2) in special cases, such as in response to a physical threat, to protect property
or defend or assert legal rights. In the event that Clintara is legally compelled
to disclose Personally Identifiable Information to a third party, Clintara will
attempt to notify the involved user unless doing so would violate the law or court
order. In addition, Clintara may disclose Personally Identifiable Information as
further described below.

Clintara operations and maintenance contractors sometimes have limited access to
Personally Identifiable Information in the course of providing services to Clintara.
Access to an individual user's Personally Identifiable Information by these contractors
is limited to the information reasonably necessary for the contractor to perform
its limited function for Clintara. Clintara requires its operations and maintenance
contractors to: (1) protect the privacy of any individual user's Personally Identifiable
Information consistent with this Privacy Policy, and (2) not use or disclose Personally
Identifiable Information for any purpose other than providing Clintara with services,
as required by law.

EU/US Safe Harbor
Clintara adheres to the Safe Harbor Principles agreed to between the United States
Department of Commerce and the European Commission in connection with the transfer
of personal information between member states of the European Economic Area and
the United States. For more information regarding the EU/US Safe Harbor principles
and Clintara's policy addressing it, please see our
Safe Harbor Privacy
Policy.

Safe Harbor Policy

Clintara, LLC (“Clintara”) respects individual privacy and is committed to maintaining
the privacy and security of the personal information of our customers, employees,
business partners and others with whom we interact. This Safe Harbor Privacy Policy
(the “Policy”) sets forth the privacy principles that Clintara follows with respect
to transfers of personal information between member states of the European Economic
Area (“EEA”) and the United States.

SCOPE
This Policy applies to all personal information received by Clintara in the United
States from the EEA in any format including electronic or hard copy.

DEFINITIONS
“Clintara, LLC” means Clintara and any of its subsidiaries, divisions, successors
and assigns. “Personally Identifiable information” means any information or set
of information that identifies or is used by or on behalf of Clintara to identify
an individual. Personally identifiable information does not include information
that is encoded or anonymized, or publicly available information that has not been
combined with non-public personal information. “Sensitive personal information”
means personally identifiable information that reveals race, ethnic origin, political
or religious beliefs or personal information regarding health conditions.

PRIVACY PRINCIPLES
The privacy principles in this policy are based on the Safe Harbor Principles.

NOTICE
When Clintara directly collects personal information from individuals in the EEA,
it will (1) disclose the purpose for collecting and using the personal information,
(2) describe the types of entities to whom disclosures may be made, (3) describe
the choices and means, if any, offered by Clintara to individuals to limit the use
and disclosure of information and (4) provide contact information to individuals
where their inquiries or complaints can be addressed. Notice will be provided at
the time when individuals are first asked to provide personal information or as
soon as practicable.

CHOICE
Clintara will offer individuals the opportunity to opt-out of further uses or disclosures
when their personal information will be disclosed to a non-agent third party or
in connection with a purpose other than the purposes for which it was originally
collected or authorized by the individual. If the use or disclosure involves sensitive
information, Clintara affords individuals the opportunity to explicitly opt-in to
such use or disclosure when the sensitive information would be disclosed to a non-agent
third party or in connection with a purpose other than the purposes for which it
was originally collected or authorized by the individual.

DATA INTEGRITY
Clintara will use personal information in its possession only in ways that are compatible
with the purposes for which it was collected or subsequently authorized by the individual.
Clintara will take reasonable steps to ensure that personal information is relevant
to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS
Clintara will obtain adequate assurances from its agents and other business partners
that they will safeguard personal information in a manner consistent with this policy.

ACCESS AND CORRECTION
Clintara will grant individuals reasonable access to personal information that it
holds about them, unless such access would compromise the purpose for which it was
collected such as blinded clinical research data during the trial. Clintara will
take reasonable steps to assist individuals with correcting, amending or deleting
personal information that is determined to be inaccurate or incomplete.

SECURITY
Clintara will take reasonable precautions to protect personal information in its
possession from loss, misuse and unauthorized access, disclosure, alteration and
destruction.

ENFORCEMENT
Clintara will verify its adherence to this Policy by conducting routine compliance
audits of its relevant privacy practices. Clintara will take appropriate disciplinary
action, consistent with applicable laws, against any Clintara employee who willfully
violates or seeks to circumvent this Policy or who takes an action to compromise
the integrity or safety of personal data.

DISPUTE RESOLUTION
Any questions or concerns regarding the use or disclosure of personal information
should be directed to Clintara at the address given below. Clintara will investigate
and attempt to resolve complaints and disputes regarding use and disclosure of personal
information in accordance with the principles contained in this Policy. For complaints
that cannot be resolved between Clintara and the complainant, Clintara has agreed
to participate in the dispute resolution procedures of the panel established by
the European data protection authorities to resolve disputes pursuant to the Safe
Harbor Principles.

LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by Clintara to these Safe Harbor Principles may be limited to the extent
(1) required to respond to a legal or ethical obligation, or (2) expressly permitted
by an applicable law, rule or regulation, such as processing data specifically requested
by government agencies for the purpose of medical safety.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to Clintara by mail
as follows:

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY
This Policy may be amended from time to time, consistent with the requirements of
the Safe Harbor Principles. Clintara will undertake annual self-certification in
compliance with the Safe Harbor requirements for continued registration. CHANGES
TO THIS SAFE HARBOR PRIVACY POLICY This Policy may be amended from time to time,
consistent with the requirements of the Safe Harbor Principles. Clintara will undertake
annual self-certification in compliance with the Safe Harbor requirements for continued
registration.

Legal Disclaimer

This website is a resource which is intended, but not promised or guaranteed, to
be correct, complete and current. All information on this website is subject to
change without notice. The information that appears on this website has been compiled
in good faith by Clintara, LLC ("Clintara") solely for the purpose of providing
information about the company and the products and services that it offers. Clintara
and/or its suppliers may make improvements and/or changes to the information, products,
services, graphics, video, sound, images, and/or programs on this website (collectively,
"Information") at any time. Clintara makes no commitment and disclaims any duty
to have these materials updated at all times.

Permission to use documents such as white papers, press releases, data sheets, etc.
from this website is granted, provided that (i) the copyright notice below and this
permission notice appear on each use of such documents; (ii) such use is for informational
and non-commercial or personal purposes only; and (iii) documents are not copied
or posted on any network computer or broadcast in any media. No modifications of
any Information is permitted. Use for any other purpose is expressly prohibited
by law. Documents specified above do not include the design or layout of the
www.clintara.com website or any other Clintara owned, operated, licensed
or controlled site. Elements of Clintara websites are protected by trade dress and
other laws and may not be copied or imitated in whole or in part. No logo, graphic,
sound or image from any Clintara website may be copied or retransmitted unless expressly
permitted by Clintara.

CLINTARA AND/OR ITS SUPPLIERS MAKE NO REPRESENTATIONS ABOUT THE SUITABILITY OF THE
INFORMATION FOR ANY PURPOSE. ALL INFORMATION IS PROVIDED "AS IS" WITHOUT WARRANTY
OF ANY KIND. CLINTARA AND/OR ITS RESPECTIVE SUPPLIERS HEREBY DISCLAIM ALL WARRANTIES
AND CONDITIONS WITH REGARD TO THIS INFORMATION, INCLUDING ALL IMPLIED WARRANTIES
AND CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT.
IN NO EVENT SHALL CLINTARA AND/OR ITS RESPECTIVE SUPPLIERS BE LIABLE FOR ANY SPECIAL,
INDIRECT OR CONSEQUENTIAL DAMAGES OR ANY DAMAGES WHATSOEVER RESULTING FROM LOSS
OF USE, DATA OR PROFITS, WHETHER IN AN ACTION OF CONTRACT, NEGLIGENCE OR OTHER TORTIOUS
ACTION, ARISING OUT OF OR IN CONNECTION WITH THE USE OF THE INFORMATION.

Clintara does not accept responsibility for other organizations, businesses, and
private persons that may provide information on this website. Any links on this
website may cause you to leave the Clintara website. The linked sites are not under
the control of Clintara and Clintara is not responsible for the contents of any
linked site or any link contained in a linked site, or any changes or updates to
such sites. Clintara is providing these links to you only as a convenience, and
the inclusion of any link does not imply endorsement by Clintara of the site. Clintara
is not responsible and assumes no legal liability for the accuracy of the contents
or any other aspect of any external website to which a link or other reference has
been provided in this website.

All brand, product, service, and process names appearing on this website are trademarks
of their respective holders. Reference to or use of a product, service, or process
does not imply recommendation, approval, affiliation, or sponsorship of that product,
service, or process by Clintara. Nothing contained herein shall be construed as
conferring by implication, estoppel, or otherwise any license or right under any
patent, copyright, trademark, or other intellectual property right of Clintara or
any third party, except as expressly granted herein.

In the event any user of the Clintara website provides any information, including,
but not limited to, questions, comments, or ideas, through any interactive mechanisms
located herein, Clintara shall have no obligation of any kind with respect to such
information and shall be free to reproduce, use, disclose, and distribute such information
to others without limitation.